The European Banking Authority has published an opinion on the application of the principle of proportionality to remuneration provisions in CRD IV. The EBA states that the extent to which smaller firms can take advantage of this principle of proportionality has raised issues of interpretation for firms and competent authorities. The EBA believes that it is essential to establish a more harmonised approach and recommends that the CRD IV Directive should be amended to, amongst other things: (i) exclude certain small, non-complex firms from the requirements to apply the remuneration principles regarding deferral and payment in instruments for variable remuneration; and (ii) limit the scope of the remuneration principles in respect of staff who receive low amounts of variable remuneration, including in large firms. The EBA's opinion is based on responses to its March 2015 consultation on draft guidelines on sound remuneration policies under CRD IV.